Last updated: 2026/7/29
Effective Date: 2026/8/11

For providing you with “Cuein iOS”( the “App” or “Software” ) and related services ( “Services”), Cuein iOS Development Team( “we”, “our”, or “us”) needs to collect some private information about you. We understand the importance of protecting your privacy. Therefore, we have established this Privacy Policy to explain how we treat your information and protect your privacy when you use the Software and the rights and options available to you regarding your information.
1.Policy Applicable Scope
This Privacy Policy illustrates our mechanisms for processing your personal information and protecting your privacy as you access our mobile applications and matching services (the “Services”), and spells out all your available rights and adjustable options concerning your personal information. We consider it your inherent right to receive full explanation of our data gathering and utilization practices associated with your use of the Software and Services. A variety of functions and content produced and supplied by us are included within the Software and Services.
once you access, view or use the App, we consider you to consent the terms and conditions described in this Privacy Policy. If you do not agree with this Privacy Policy, please stop using the App immediately.
This Policy applies solely to data gathered within our App and via electronic communications (email, text, etc.) connected thereto. It does not extend to information collected by other applications or websites, including third-party sites accessible through the App. We advise you to review their privacy policies before furnishing any data.
2.User Age Restriction
Access to and use of this App shall be restricted to persons who are at least 18 years of age or who have attained the legal age of majority as established by the applicable laws and regulations of the jurisdiction in which they reside (such age being referred to herein as the “Minimum Legal Age”).
We do not intentionally collect any information from, or direct any marketing activities toward, any children, minors, or individuals who have not yet reached the Minimum Legal Age. If you have not yet attained the Minimum Legal Age, you shall refrain from making any use of this App and shall not submit any personal information through any of the App’s functions or features.
Should we become aware that any person below the Minimum Legal Age has registered an account with us or has provided personal data to us, we shall promptly take steps to terminate that user’s account and permanently erase all personal information associated therewith, without any undue delay.
If you have reason to believe that we hold any personal data pertaining to an individual who is under the Minimum Legal Age, please contact us via the email address specified at the conclusion of this Policy.
We place great emphasis on the safety and privacy protection of children. To that end, we have prepared a dedicated detailed CHILD SAFETY RULES. You may view its full text through the following link: https://resource.cueinapp.com/Cuein/1783996734062.html.

3.Information We Collect
3.1 Information you provide
1)Account Information
When you create an account (“Account”), you may volunteer to provide certain information (“Account Information”) about yourself to the Software, such as username, gender identity, phone number, date of birth, preference, personal introduction, photos, profile image and other detailed information.

2)Your Content
Your Content includes any content you create, import, upload, send, publish, generate, receive or store through the Software or Services (including any content generated by the artificial intelligence features we may provide, if applicable), including without limitation photos, videos, texts, profile avatars, audio recordings and other related materials (collectively referred to as “Your Content”).
Keep in mind that viewers of your photos, chats, or other shared items can always take screenshots, save them, or copy them elsewhere. So please avoid sharing anything you wouldn’t feel comfortable having others keep or pass on.

3)Sensitive Personal Information
Information you provide may contain sensitive personal information within the meaning of relevant state privacy legislation. Our processing of such data is governed by applicable legal requirements, specifically to deliver the Services and for other authorized purposes set forth under state laws, including the California Consumer Privacy Act (“CCPA”). You have the sole election whether to include sensitive personal information in your user content or other voluntary submissions. As defined under statutes like the CCPA, sensitive personal information explicitly encompasses racial or ethnic origin, national origin, religious beliefs, physical or mental health diagnoses, sexual life or orientation, transgender or nonbinary identity, citizenship or immigration status, and financial information. We do not require that you supply this information. Nevertheless, if you choose to post user content relating to these topics, please be aware that such content may be rendered visible to other users and the public, subject to the parameters of your privacy settings.

4)Permission to Access Storage
To ensure that you may save photos or cache information normally to your device, you may voluntarily grant us permission to access the storage of your device.

5)Support Related Information
If you communicate with us via our support section or via email, we may collect your email address and other information you send to us.

6)Information for Commercial Activities
If you participate in any activities within the Software, for example, expressing interest in a particular commercial offering, or liking, commenting on, or taking part in a commercial campaign, we may, for the purpose of improving the effectiveness of such activities, collect your username, profile avatar, and other information relating to your activities on the Software. Such information may be associated with advertisements, promotional offers, and other sponsored or commercial content displayed by us across the Software.

3.2Information that is processed automatically
1)Device Information.
We may collect information about your device when you use the Software, including your configuration and settings of the Software and Services, version of the Software and Services; ISP (Internet Service Provider), Internet protocol (IP) address, device configuration and identifiers.

2)Usage Information.
We may collect certain usage information relating to your use of and interaction with the Software, including but not limited to: the duration and frequency of your use of the Services; and your interactions with other users, such as comments, likes and reports.
We may automatically analyze your usage information, either based on your configured preferences or through computer-programmed algorithms, for the purpose of predicting your preferences. Such analysis enables us to provide you with enhanced friend recommendation services.

3)Face Data.
A.Collection and Processing of Face Data
When you upload a photo for the purpose of setting your profile avatar, we solely employ CIDetector (provided within Apple’s Core Image framework) to detect the presence of a human face in the photo. Should no face be detected, the Software will prompt you to re-upload.

B.Storage and Sharing of Face Data
Where certain features are enabled through third-party AI providers, we may share the facial photos you upload with such providers.
We will store your facial photos only when you upload them as your profile avatar, and such storage is limited to displaying the avatar you have set. Beyond this, neither we nor third parties will store any other face data. (For further details on biometric information processing, please refer to Section 3.4 below.)

3.3 Information from Other Sources
We may receive the information described in this Privacy Policy from external sources, which may include the following:
1)If you choose to sign up or log in to the Services through a third-party service, we may collect your publicly available profile information and email address from that service.
2)Information concerning you may be provided to us by other users or third parties, for example, where you are identified or mentioned in user content, correspondence, or in any complaint, appeal, request, or feedback directed to us, or where your contact information is transmitted to us by others.

3.4 Processing of Biometric Information
1)Definitions
A.The terms “biometric identifier” and “biometric information” shall be construed in accordance with the Illinois Biometric Information Privacy Act (740 ILCS 14, “BIPA”), the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”), the Children’s Online Privacy Protection Act (“COPPA”), the CCPA and all other applicable privacy laws worldwide.
B.“Biometric identifier” means retina scans, iris scans, fingerprints, voiceprints, facial geometry scans and other physiological or behavioral biometric markers. Categories excluded under Section 10 of BIPA shall not be deemed biometric identifiers hereunder.
C.“Biometric information” means any data derived from a biometric identifier that can identify a natural person. Raw photographs, videos and audio files do not constitute biometric information unless they undergo dedicated technical processing for the purpose of unique individual identification or authentication.
(“Biometric identifiers” and “biometric information” hereinafter collectively referred to as “Biometric Information”)
D.“Third-Party Provider” means vendors we cooperate with to deliver content moderation and artificial intelligence technical services.
2)Written Consent
A.By clicking to accept this Privacy Policy, you grant our express written consent and authorization permitting us to collect, store, transmit, process, retain and disclose Biometric Information contained in Your Content, for purposes including but not limited to: a) Normal display, playback and sharing of Your Content; b) Collecting and analyzing images, voices and text contained in Your Content via Third-Party Providers to detect and filter illegal or objectionable content; c) Processing materials you input into the Software via Third-Party Providers’ AI tools, generating corresponding outputs in accordance with your instructions and screening both input materials and AI-generated content for illegal or objectionable material; d) Enforcing this Privacy Policy, Terms of Service and COMMUNITY CONTENT CODE, and removing violating content as required by applicable laws; e) Complying with statutory reporting obligations, regulatory inquiries and court orders; f) Maintaining basic operation of the Software under the data minimization principle.
B.If any third-party individual appears in any video, photograph or audio content you post or intend to post, by uploading such content, you represent and warrant that you have obtained the prior explicit informed consent of such third-party or its guardian (if required by law) permitting us to collect, analyze and process their images, voices and all other information contained in the content as set forth in this Privacy Policy.
C.You acknowledge and agree that Your Content you upload to the Software may contain Biometric Information as defined under applicable laws. By uploading content bearing your facial images, voices or other Biometric Information, you confirm that this Privacy Policy constitutes the written notice required by law, and we hereby disclose the following processing methods to you:
a)Scope of Processing – No Biometric Identification.
Notwithstanding the consent you grant us to use your Biometric Information, the Software does not currently deploy any native functional modules, algorithms or commercial tools engineered to actively extract, scan, analyze, match or independently exploit facial, fingerprint or other biometric templates for user identity authentication, targeted advertising, automated user behavioral profiling or cross-platform user tracking.
Neither we nor our Third-Party Providers will utilize facial or voice data from your uploaded content to identify you or any third-party individuals featured therein.
Our processing of Your Content as set forth in Items (b) and © of this Section shall not be deemed the “collection” or “capture” or “storage” or “use” of Biometric Information under applicable laws, and we are not a “private entity in possession of biometric identifiers or biometric information” within the meaning of BIPA.
b)Content Moderation – Image, Voice and Text Analysis.
To deliver a safe and wholesome service experience for all users, we will collect and analyze images, voices and text contained in Your Content that you intend to post on the Software via Third-Party Providers. The sole purpose of such analysis is to detect and filter illegal or objectionable content, and prevent any such content from being published on the Software. This analysis involves no extraction or processing of Biometric Information. Image review is conducted on an overall photograph level only (e.g. detecting prohibited visual materials), without measuring or extracting facial geometry, interpupillary distance or any other biometric features. Audio review is conducted on the whole audio track (e.g. detecting prohibited verbal content), without extracting or processing voiceprints for identification purposes.
c)AI Features (If Applicable).
When you utilize AI Features of the Software (e.g. AI image editing), we will collect texts, images and other materials you input, and share such data with Third-Party Providers. Third-Party AI tools will recognize your requests and generate corresponding outputs per your instructions; meanwhile, Third-Party moderation systems will detect both your input materials and AI-generated content to filter illegal or objectionable materials. The sole purpose of processing texts, images and audios via AI Features is to produce edited derivative works, rather than biometric identification or authentication.
3)Retention and Destruction Policy
Although we do not collect, capture or store Biometric Information as defined under applicable laws and thus hold no Biometric Information subject to mandatory retention or destruction requirements, we maintain a publicly available written retention and destruction policy for all files that may incidentally contain Biometric Information as required by applicable laws:
a)We will not intentionally collect or retain any Biometric Information;
b)If we incidentally obtain any Biometric Information in the course of processing Your Content, such information shall be permanently deleted upon the earlier of: (i) full fulfillment of the original processing purpose; or (ii) three calendar years after your last interaction with the Software; and
We may extend the retention period solely where a valid warrant or subpoena issued by a court of competent jurisdiction mandates data preservation.
4)Prohibition Against Commercial Exploitation
We shall not sell, lease, trade or derive any commercial gains from any Biometric Information contained in Your Content.
5)Restrictions on Disclosure of Biometric Information
We will not disclose Biometric Information to any third party unless one of the four legal exceptions below applies:
a)You provide separate specific written consent for such disclosure;
b)Disclosure is necessary to complete a transaction initiated and authorized by you;
c)Disclosure is required by applicable laws and regulations; or
d)Disclosure is compelled by valid court orders, warrants or subpoenas.
The limited data sharing with Third-Party Providers for content moderation and AI Features under this Section 2), C shall not constitute prohibited disclosure.
6)Data Security Standards
A.We adopt the reasonable standard of care prevailing across the social media industry to encrypt, store and transmit all user content that may incidentally contain Biometric Information, and prevent unauthorized access or data leakage.
B.The technical, administrative and physical security safeguards we deploy for materials bearing Biometric Information shall be equal to or more stringent than those applied to other confidential and sensitive personal information in our systems.
7)Statutory Rights of Users
A.You are entitled to the rights of access, rectification, erasure, restriction of processing, data portability, objection and withdrawal of consent in respect of your Biometric Information. Details of each right and exercise procedures are set forth in Section 11 of this Privacy Policy.
B.If you withdraw your consent to processing Biometric Information, such withdrawal shall not affect the lawfulness of all processing activities conducted prior to withdrawal based on your original consent.

4.How We Utilize the Information Collected
We shall employ the information we collect for a variety of purposes, all of which are directed toward the provision and enhancement of our Services and the maintenance of safety. Such purposes shall include the following:
1)The operation and administration of the Services, which shall encompass enabling the creation, sharing, and interaction of content, user support, and other core functionalities.
2)The support of social features, including the connection of users, the suggestion of accounts, and the facilitation of sharing and interaction with user content.
3)Communication with you, including the notification of service changes.
4)The conduct of marketing, promotional, and brand‑building activities for our Services and affiliated offerings, including the use of Your Content on social media, app stores, websites, events, and other cooperative channels.
5)The review, support, improvement, and development of the Services, as well as the training and refinement of underlying technologies (such as machine learning models) by analyzing usage, soliciting feedback, monitoring cross-device activity, and scrutinizing user content, messages, AI interactions, and metadata.
6)The assurance of safety, security, and stability by addressing technical issues, spam, and abuse, and by detecting fraud and illegal activity.
7)Compliance with legal obligations and the protection of our legal rights, commercial interests, and those of our affiliates, users, and the public.
8)The carrying out of other purposes disclosed at the point of collection or based on your consent.
We may also combine information obtained from different sources in order to fulfill any of the aforementioned purposes.
If you are situated within the European Economic Area (EEA), the United Kingdom, or Switzerland, we shall process your personal data on the following legal bases:
(i) Performance of a Contract (corresponding to purposes 1, 2, and 3 above): processing that is necessary to provide the Service you requested, including account creation, matching, and communication features;
(ii) Consent (corresponding to purposes 4 and 8 above): for the processing of sensitive data (including facial/biometric information and precise location data), marketing communications, and optional features;
(iii) Legitimate Interests (corresponding to purposes 5 and 6 above): for security monitoring, fraud prevention, service improvement, and analytics, where our interests are not overridden by your rights and freedoms;
(iv) Legal Obligation (corresponding to purpose 7 above): to comply with applicable laws, regulations, and legal processes. Where processing is based on consent, you may withdraw your consent at any time, and such withdrawal shall not affect the lawfulness of processing carried out prior to such withdrawal.

5.Sharing Information with Third Parties
We will share your information with third parties only in the ways that are described in this Privacy Policy.
1)Third-party APIs. We integrate the Doubao Seed 1.8 API to deliver artificial intelligence-based functionalities to you. Specifically, these functionalities operate in the following manners: (i)When you submit a textual prompt to the API instructing it to generate chat scripts or related recommendations, the API will process your input and generate corresponding content accordingly; (ii) where your prompt requests the recommendation of user cards, the API will, on the basis of the user tag categories specified in your prompt, screen and present to you those user cards bearing the designated tags; (iii) where your prompt commands the display of your tag repository, the API will retrieve and render your complete tag library for your review.
For the purpose of ensuring the normal operation of the functionalities set forth above, we will share with the provider of the Doubao Seed 1.8 API the textual prompts and other input data that you actively submit, so that the API may generate corresponding content in accordance with your instructions. This sharing is strictly limited to fulfilling your current generation request. The API providers are contractually obligated not to retain your original images for any other purpose after processing, except as may be independently required by their own privacy policies (in which case we require them to adhere to the principle of data minimisation and to assume responsibility for data protection).
Your Choices and Impact of Refusal: If you do not wish us to share your images with these APIs, you may contact us via the email address provided at the end of this Privacy Policy. Please be advised, however, that if you choose not to permit the sharing of the aforementioned information or disallow the use of these APIs, the related functionalities that depend on this processing will be unavailable to you. This refusal will not affect your use of other basic features of the App.
We impose strict compliance requirements on the API providers we engage, and we require them to protect your personal information at levels no less stringent than those set forth in this Privacy Policy. We share your information solely for the purpose of delivering the generation services you have explicitly requested, and we do not use or permit the use of such information for any unauthorised purposes.

2)Other Third-Party Service Providers. In addition to the API partners described above, we may share your information with certain third parties (including, without limitation, search engines, content providers, and advertising networks and platforms) that provide various services (such as advertising, marketing, analysis, content, and search) in connection with the Software and the Service, or these third parties may directly collect your information through the Software or their SDK. We take appropriate measures to ensure that no user can be individually identified from the disclosure of such information, and we require these third parties (i) to keep the data secured, (ii) not to use the data for any other purpose other than to provide us with the Service; and (iii) to use the data solely in compliance with the applicable data protection laws and this Privacy Policy.
If you want to delete any personal information which we have shared with the third parties, please contact us through the email displayed below. We would try our best to notify the third-party of deleting the relative personal data, but no warranty as to the deletion is made by us.

3)Required by law. If we are required by law to disclose your information, we may share your information with law enforcement or other competent authorities and any third party, as may be required (e.g., to detect, prevent or otherwise address fraud, security, or technical issues; to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of the other users, our partners, or the general public).

4)Business Transfers. In the event that we or any of our affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organization, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal information.

5)With Your Consent. We may share your information for other purposes pursuant to your consent or at your direction.

6.Modifying Your Registration Information
You may access or modify the Registration Information you provided. When your Account is deactivated, we take reasonable efforts to make sure it is no longer viewable on the App. We are not responsible for any information, pictures, comments, or other content that is deleted from our systems resulting from the deactivation of your Account.
Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by other users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. If you have given third-party applications or websites access to your personal information they may retain such information to the extent permitted under their terms of service or privacy policies.

7.Changes to this Privacy Policy
As the App evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information. By continuing to access or use the App after changes to this Privacy Policy become effective, you agree to be bound by the revised Privacy Policy.

8.Security
We take commercially reasonable security measures to help protect your information against loss, misuse and unauthorized access, or disclosure.
Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:
a. Please make sure you log out of your Account after use as you never know who may stumble onto your Account;
b. Please don’t share your Account password with anyone else!
c. Change your Account password periodically.
If you ever think someone has had access to your Account password, please report it to us and change your password immediately.
Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.
WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ANY BREACHES OF SECURITY, DAMAGE TO YOUR DEVICE, OR ANY LOSS OR UNAUTHORIZED USE OF YOUR REGISTRATION INFORMATION OR OTHER DATA.

9.International Data Transfers
To deliver Services to you, the information described in Section 3 (“Information We Collect”) is stored and processed on servers located in the United States, hosted by third-party cloud service providers. Our operation team primarily in Hong Kong may access and review certain user information for purposes including service maintenance, customer support and safety monitoring.
Whenever we transfer your information to jurisdictions outside your country of residence, we ensure that such transfers are carried out in compliance with your local legal requirements, to ensure that your personal information receives an adequate level of protection. While such information is outside of your jurisdiction of residence, it is subject to the laws of the jurisdiction in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other jurisdiction, pursuant to local laws.
If you are situated within the European Economic Area (EEA), the United Kingdom (UK) or Switzerland, we rely on the Standard Contractual Clauses (“SCCs”) approved by the European Commission as the appropriate transfer mechanism for such cross-order data flows. Where personal data is transferred from the EEA, the UK or Switzerland to the United States or to Hong Kong, such transfers are conducted in accordance with applicable data protection laws. We implement appropriate safeguards, including SCCs, to ensure that your personal data receives an adequate level of protection during such transfers. Our relevant entities located in China are granted limited remote access to the information described in “Information We Collect” for the purpose of performing essential operational functions only, and is bound by confidentiality obligations and our internal data access policies.

10.Duration of Data Retention
The period for which we shall retain your information shall be determined by reference to the minimum duration necessary for the delivery of the Services and for the execution of the other activities set forth in this Privacy Policy. We may also preserve your information beyond such period under the following circumstances: (1) where retention is mandated by applicable legal or contractual provisions; (2) where we possess a valid business justification for retaining the data, including but not limited to purposes of service improvement, development, and the maintenance of safety and stability; and (3) where the information may be required for the pursuit or defense of legal claims.

11.Your Rights Concerning Personal Data
You are vested with the right to delete your Account, as well as the right to access, modify, correct, or erase any personal data that we may have collected from you, subject to the laws of your jurisdiction. To exercise any of these rights, please contact us via the email address set forth below. We shall verify your identity prior to processing your request and shall respond within the timeframes prescribed by applicable law (generally within 30 days). Should we decline to act upon your request, we will provide you with the reasons for such declination and inform you of your right to appeal or to lodge a complaint with the competent supervisory authority.
You may also be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, you shall provide evidence that you have granted such agent power of attorney or that the agent otherwise holds valid written authority to submit requests for the exercise of rights on your behalf. We will respond to your request in a manner consistent with applicable law and subject to proper verification. We will verify your request by asking you to send it from the email address associated with your account or to provide such other information as may be necessary to verify your account.

12.How to Reach Us
If you have any inquiries concerning the Service or this Agreement, or if you wish to obtain a previous version of this document, or if you desire to exercise any of your privacy rights, please do not hesitate to contact us at AetatisTeam@outlook.com.